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The mechanism of whiplash is not well understood and thus preventing a certain motion or force in an occupant might not mitigate this injury. However, a number of injury criteria have been proposed to evaluate the neck injury risk in a rear-end crash. In the safety design of the seat and the headrest assembly, robustness or invariability of whiplash protection must be secured not only under the assessment pulses applied in sled tests but also under such pulses that show random multiple peaks in real-world car-to-car rear-end crashes. The aim of this study is to investigate a method of evaluating the invariability of whiplash protection performance in low-speed rear-end crashes, not with multiple injury criteria but with a single newly proposed objective function. The function was determined based on the hypothesis that the ideal seat is rigid in terms of such invariability.